BROWNFIELDS/LAND RECYCLING

The Phoenix Group, LLC recently announced the implementation of a large Brownfields redevelopment project in Manheim, Pennsylvania. The location is the former Raymark Industries Manufacturing facilities, where manufacturing operations ceased several years ago. RT has been active at this site since 1995, having assisted the Company with closure of a RCRA landfill at the site.

The Manheim project presented a number of difficult technical and logistical challenges. Due to litigation surrounding asbestos products manufacturing, an initial bankruptcy in the early 1990’s had allowed for reorganization of assets, and continued asbestos manufacturing for products which have no substitute, by Universal Friction Composites (UFC). UFC continued limited operations at the facility and Raymark Industries, in the mid-1990’s, remained as landlord at the facility. Raymark began discussions in 1996 with the Pennsylvania Department of Environmental Protection, following promulgation of the Act 2 Land Recycling Program to find out how to address environmental issues at the site.

However, hopes for Brownfields redevelopment were dashed when the Company was drawn to a second bankruptcy, related to ligation surrounding its former Connecticut operation, which had become a Superfund Site. Due to the attractiveness of the Act 2 Program in Pennsylvania, however, both Raymark’s upper management and a subsequent bankruptcy trustee wanted to take advantage of the Pennsylvania Land Recycling Program, to obtain cleanup liability protection for releases at the site. As the direction became clear as to how to resolve issues involved in the second bankruptcy, RT was engaged to:

• finish the RCRA landfill closure and adjacent wetlands restoration work;

• consolidate waste materials for future removal;

• conduct a site investigation to determine what releases to soil and/or groundwater were of concern;

• remove underground storage tanks at the facility.

In addition to the normal Land Recycling investigation work, due to the presence of Chiques Creek and Doe Run , which run through and adjacent to the facility, RT implemented upstream and downstream water sampling, which showed non-detect concentrations for key constituents of concern, including lead. A key issue RT was able to resolve regarding the historical waste products, was that tetraethyl lead used in the compounding of the friction products (including brake shoes), was compounded in such a way that leachability was minimal. This finding helped to resolve a key technical question - why hadn’t monitoring wells near the RCRA landfill, shown impacts to groundwater, even though the compound product itself tested as characteristic hazardous for lead? RT comprehensively reviewed historical groundwater monitoring data, and conducted waste characterization leaching tests, which showed that the leachability from the material is minimal.

Given the complexity of the site, and need for real time decision making, RT requested that the Pennsylvania Department of Environmental Protection to assist with weekly field meetings, so that the Land Recycling investigation process could be as focused and as efficient as possible. Pennsylvania DEP’s South Central office Environmental Cleanup Program was instrumental in providing assistance, assigning a hydrogeologist to work closely with RT as initial investigation work showed what releases would need Act 2 cleanup liability protection at the site. Solvent impacted groundwater as well as an historical asbestos products landfill, and storage tank releases will be the subject of the Act 2 Land Recycling process. Deteriorating buildings where asbestos products were manufactured are also of concern, and a redevelopment plan is under discussion with Borough officials, which is expected to call for demolition of a large portion of the Lower Mill buildings, which have little future useful life, and which are asbestos contaminated. The Borough, understanding the situation, had the site designated a Keystone Opportunity Zone, which helps facilitate redevelopment by offering tax abatements.

A portion of the Lower Mill lies in the floodplain, and Manheim Borough has been instrumental in providing a new city park, on land on the opposite side of Chiques Creek, so Manheim is a leader in proper use of the floodplain through its overall planning process. The redevelopment plan takes into account proper floodplain use on the mill side of the creek as well.

Herman Ramig, long-time Engineering Manager at the property, has worked very hard to keep the property viable, by attracting various tenants who have workshops, auto reconditioning facilities, as well as storage operations at the site. Gary Silversmith of the Phoenix Group, LLC announced that the Upper Mill facilities, which are newer and were constructed after World War II, are expected to attract a variety of industrial and commercial tenants, as more space becomes available in the coming months and years, following the decommissioning of the remaining manufacturing operations in a number of the buildings. An additional focus is on twenty-seven (27) acres of undeveloped expansion area, which has direct rail access by Norfolk Southern, and could attract new industries to the mill complex. Also being considered is conversion of the Company mid-rise office building to a Technical Center, with high-speed Internet access. Manheim Borough has been planning for resurgence of the Mill property in recent years, and has already made application for funds to provide improved access to the Mill complex from Fruitville Pike, which will minimize future commercial and industrial traffic through narrow Borough streets.

Pennsylvania is one of the only states in the nation where successful Brownfields initiatives such as that used at this Mill complex, can be handled in both an efficient and "transaction" timeframe manner. Doug Lashley and Nick Rudi, of the Phoenix Group, LLC are also hard at work on additional grant and redevelopment opportunities, as well as sensitive future use of the floodplain, which constitutes a number of acres at the property. Mr. Lashley has in-depth expertise on wetlands restoration projects, and the redevelopment plans of the property will take the unique situation of a creek and tributary confluence and floodplain at the site into account.

Although there are a number of important issues to still deal with at the Mill complex, the attractiveness of Act 2 cleanup liability protection, cooperative assistance from the Pennsylvania Department of Environmental Protection’s South Central office, and flexible Land Recycling options available, proves that Pennsylvania’s award-winning Act 2 Land Recycling Program works, even in the face of obstacles including limited funds, a RCRA landfill, and a double bankruptcy.

Lancaster County’s growing economy, along with the availability of grants and loans to help facilitate redevelopment of the Mill complex, means that better days are ahead for Manheim, as the Mill complex which was becoming an eyesore, now has a bright redevelopment future, with Act 2 Land Recycling cleanup liability protection being available to help facilitate the redevelopment process. Tom Showers, Manheim Borough Council President, has indicated that the Borough wants to work with the new owners, to help make the redevelopment project a success.

Project Participants:

• Redevelopers
  Gary Silversmith, Doug Lashley, Nick Rudi
• Raymark Industries
  Herman Ramig
• Trustee
  Wendy Shapss, Laureen Ryan
• Manheim Borough Officials
  Tom Showers, Charles Lyon, Rob Stoner
• DEP Officials
  Patty Romano, Eric Rooney
• RT Staff - 
  Matt Martelli and Chris Orzechowski -
  Tank Removal & Field Investigations
   Larry Bily - Waste Inventory & Consolidation
  Gary Brown, P.E. - Principal-in-Charge

PEOPLE WHO MAKE BROWNFIELDS HAPPEN!
Profile: Herm Ramig

All of those who participate in engineering projects know that there are key individuals who are instrumental in making things happen. Some individuals, due to their commitment and attention to detail, make projects much more smooth and efficient than they otherwise could or would be. One such individual is Herm Ramig, the person with "all the knowledge and commitment" at the former Raymark Industries, Manheim plant.

Mr. Ramig, a key engineer at the plant, worked there since the 1970’s, through thick and thin. When manufacturing scalebacks occurred, he kept the mill buildings occupied by bringing in tenants and handled extensive utility conversions when utility and boiler operations were shutdown. Landfill cap problems (groundhog holes) were addressed by grabbing a shovel and doing the work, something few people with 30 years at a plant are willing to do.

To facilitate the Land Recycling process, he assisted RT with:

• Frequent and in-depth research on units, tanks and historical uses.

• Calling former employees and managers to answer key questions on historical waste management practices. 

• Being up early and working late to facilitate long schedules for investigation and tank removal work. 

Even though money was scarce when manufacturing operations ceased, Mr. Ramig saw to it that tanks were pumped out and waste was consolidated into safe ares. He also kept the Mill buildings in safe condition, and quickly responded to a fire caused by vandalism, securing the site to the satisfaction of Borough officials. What makes the difference? When you have an outstanding individual who cares about a site, Land Recycling is so much easier because the work is focused with full, knowledge of historical operations and far fewer "unknowns" to deal with.

We at RT salute Herm Ramig as proof that people who care make all of the difference. Having an individual like Mr. Ramig and using the Pennsylvania Award Winning Land Recycling Program means a highly efficient Brownfields effort, with quick focus on the important problems, and facilitating earlier redevelopment of the Mill complex.

(Phila. Inquirer, 10/14 & 16/00)

-Gary Brown

WOODRUFF ENERGY COMPANY - A NEW JERSEY ISRA/BROWNFIELDS SUCCESS STORY

RT Environmental recently completed upgrading of a secondary containment facility under NJDPCC regulations, for the Woodruff Energy Company, Bridgeton, NJ. Unexpected findings during the tank secondary containment upgrading project caused the need for emergency reporting to the New Jersey Department of Environmental Protection, when a long abandoned buried municipal waste water treatment plant was found beneath a former product transfer pumping station being demolished as part of the project. Following the initial finding of floating oil product, and because of concern that the waste water treatment system was still connected to the Cohansey River caused a temporary shutdown in the secondary containment upgrading project.

Woodruff Energy Company is a home heating oil, commercial business, and service station supply distribution facility, serving southwestern New Jersey. Oil storage facilities have been present on the site on Water Street in Bridgeton, even prior to Woodruff's operations, which began at the site in 1959. Historical operations included barge product delivery and railcar product delivery, although, all oil product operations in recent decades have involved product receipt and delivery by tanker truck.

Upon finding that the buried wastewater treatment plant, immediate contacts were made with the City of Bridgeton as well as the Cumberland County Utilities Authority. It was identified that a treatment system had operated on the site from 1883 until 1927, and investigation work began immediately to determine the size and extent of the buried wastewater treatment tanks at the site. DEP expressed concern that product, or dissolved product, might be migrating to the River, through unknown pipes or, the former wastewater discharge system. Drawings showed a long discharge pipe to the middle of the river.

County utility officials were instrumental in completing an immediate record search and RT worked closely with Lynne Mitchell of the New Jersey Department of Environmental Protection Southern Field Office, as well as Tim Maguire, senior DEP hydrogeologist. We began to conduct an immediate multi-phase investigation to:

• Use data logging techniques to determine whether or not the wastewater vaults were hydraulically connected to the aquifer, or river which is tidal, and verify groundwater flow direction.
• Expeditiously determine the extent of impacted soils at the facility, as some areas of product saturated soils were found in the vicinity of the wastewater vaults, and some floating product was found in the vicinity of the oil pumping station.
• Large test trenches were also excavated horizontally parallel to the river to determine and confirm that no pipelines existed which could convey product impacted groundwater to the River.
• Influent and effluent pipes to and from the wastewater treatment vaults, as well as other pipes, including product and old, small diameter terra cotta pipes encountered during the excavation were all drained and properly grouted, so that there is no potential for further migration to the nearby River.

The New Jersey DEP considers the Cohansey River to be in need of environmental protection, because of presence of shell fish beds, in the lower part of the River, in the Delaware estuary.

The entire project was conducted expeditiously, using a team approach. RT and DEP shared investigation approaches and findings on a daily basis, following a DEP visit to the site by senior officials from the Southern Field Office. With winter approaching, the key concerns were:

• Completing the investigation project such that secondary containment lining could still be installed before cold weather arrived (HDPE selected for secondary containment cannot be installed in low temperature conditions).
• As the previous secondary containment earthen berms had to be opened for the entire project, all parties felt it important to proceed with the work expeditiously, so that the secondary containment could be put back in place.
• All expressed a desire to work closely together using a high degree of careful technical focus to reach common understandings on the specific goals and need for each investigation and remedial step, and to work quickly towards a solution.

The Project turned into a model of cooperation, meeting with full intent and spirit of the New Jersey ISRA/Brownfields law. Although many people are under the impression that the Brownfields Law only applies to contaminated, abandoned urban sites, ISRA revisions also in the law actually allow DEP to adopt flexible and appropriate standards, for petroleum release sites using a risk based corrective action process. RT worked closely together with DEP to use appropriate standards as localized areas around the waste water treatment vaults were investigated, taking into account that the area would be capped by the secondary containment liner. Also taken into account were the investigation results, the site setting, and migration potential.

Once it was demonstrated that all potential migration pathways of concern to the river had been located and successfully closed, Class II soil standards were found to be applicable, and remedial needs were focused on two particular "hot spot areas", which were expeditiously remediated by excavation and removal of soil. Soil was shipped to a regional bioremediation facility for treatment. Engineering and investigation findings, as well as lab results, and key technical findings were forwarded to DEP by fax on a daily basis and investigation and remediation of the entire tank farm/wastewater treatment area was completed in a short three weeks.

There are many people who claim that investigation and remediation at petroleum sites can be overly complicated in NJ and that it can take years to get decisions and to reach a final conclusion. The fast-track project at Woodruff Energy showed that:

• New tools available as part of NJ Brownfields initiatives can allow for a rapid, technically complete remediation work, to address areas of concerns efficiently and effectively.
• Experienced regulatory professionals working closely together, can make quick decisions, carefully focused on specific technical areas, working collaboratively to address environmental concerns.

Although some view the Technical Requirements for Site Remediation in New Jersey as unnecessarily complex, environmental professionals who clearly understand them can work closely with the DEP to make fast field decisions, even when not everything is known initially about the history of a site. Unknowns can be quickly addressed using the most appropriate engineering and hydrogeologic investigation techniques to reach proper technical conclusions quickly.

Mr. Robert Woodruff, Sr., President of Woodruff Energy, commented that the level of cooperation was remarkable, in that daily investigation and remediation work could be planned and implemented with DEP oversight so as to be both focused and efficient. The project was a model of cooperation and provides the assurance that Woodruff's main tank farm facility has been through the investigation and remediation process so that areas under the liner system, are no longer of environmental concern. Woodruff Energy is starting 1999 as one of New Jersey's first ISRA/ Brownfields success stories, wherein fresh approaches and a high level of cooperation prove that environmental work can proceed quickly, efficiently, and professionally.

We at RT salute the Southern Field Office of the New Jersey Department of Environmental Protection for its highly professional and time sensitive oversight, of this important project. Without question, many property and facility owners in New Jersey will want to take advantage of new opportunities that exist to deal with site contamination issues under the New Jersey Brownfields Law.

For more information on the New Jersey Brownfields Law and associated ISRA program revision, contact Gary Brown or Tom Brady. Tom Brady can be reached at our New Jersey office (856) 467-2276 or at tbrady@rtenvnj.com.

BROWNFIELDS SITE RECYCLING IN AMERICA’S HEARTLAND

I was recently involved in a discussion with several attorneys and consultants at a bid walk when the discussion turned to the New Jersey Brownfields program. This perked my attention, as RT has several Brownfield projects underway and completed, and I was anxious to hear how others were faring in the process. To my amazement, the general consensus was that there was very little Brownfields work being undertaken in New Jersey, and who would want to work anyway with NJDEP, being as unresponsive as they are typically?

I was very surprised by this perception. First because of the general lack of green space in New Jersey and the continuing fight over the control of the green space. Second, because of efforts NJDEP now makes on many projects to meet transaction dead lines.

Municipalities and developers in New Jersey have begun a struggle to control the remaining areas of green space open for development. Municipalities have been armed with millions of dollars in the Greenfields program, to acquire farm land and other open space to be preserved as open land or parks. Additionally, municipalities have been making the land development process increasingly more difficult through the implementation of stricter environmental regulations and burdensome development requirements. These increase the costs to develop open space. Developers are entering into prospective agreements with farmers for development rights in the future, thus, effectively tying up the available land now. All of this is resulting in the reduction of greenspace available for redevelopment. This is having the overall effect of making Brownfields sites look more economically attractive.

The perception of the NJDEP was very perplexing to me. Over the past years there has been a concerted effort at NJDEP to recognize the need for quick responses when transactions are involved or when there is an immediate threat to human health or the environment. Recently I contacted the NJDEP to just check on the status of a project. The first thing the case manager asked me was "when is the transaction date?". He was relieved to hear that there was no pressing date and we had a realistic conversation regarding review times. This is indicative of the sensitivity of the NJDEP to transactions and their need to respond appropriately.

Additionally, over the past several years, the NJDEP has implemented several initiatives aimed at use of realistic risk based clean-up levels. No longer do you have to chase every molecule from a release, unless there are sensitive receptors downgradient. Groundwater can often be addressed through passive bioremediation or natural attenuation and a CEA. Impacted soils do not necessarily need to be removed or treated unless they continue to contribute to a migrating groundwater plumes. Soil can be capped and left in place with a DER and deed notice. All of this has allowed for environmental issues at sites to be dealt with more efficiently and more economically.

With shrinking greenspace and more friendly remedial approaches, NJ Brownfields sites are becoming more attractive and feasible to develop. Combine this with tax rebates, grants, and municipal tax relief and development of abandoned Brownfield sites can also be highly profitable post development.

Tax rebates are available where the developer of a Brownfield site is eligible to recover 75% of the remedial costs from the tax revenue generated from the developed property. Additionally, if the municipality designates the site as an Environmental Opportunity Zone, the property taxes can be significantly lowered for up to fifteen years, allowing the developer a chance to recover costs.

New opportunities in New Jersey for Brownfields development will undoubtedly cause more interest in these properties in the future.

Should you have any questions regarding New Jersey Brownfields projects, please feel free to contact Tom Brady at (856) 467-2276.

DOWNINGTON, PA PROJECT

A Brownfields and Land Recycling Success Story

by Gary Brown

Pennsylvania's Governor, Tom Ridge, has announced a Land Recycling grant for the former O'Brien Machinery site in Downingtown, PA. The announcement marks the largest grant ever awarded through the Industrial Site Reuse Grant program for a single project. The project has been heralded as a model of federal-state-local cooperation, being one of the first sites where residential redevelopment of a former Brownfields site is going to be achieved. Innovative PCB remediation techniques are helping to make redevelopment possible and both local and EPA officials are working with state officials to implement a "showcase" Land Recycling project.

**Bruce Beitler, PADEP Regional Land Recycling Coordinator and Gary Brown, President of RT, discussing the recently awarded contract with a Downingtown official.**

Site History

The 22 acre site was a foundry in the 1800's and eventually became an electrical equipment repair and refurbishment facility in the middle of this century. Very large electrical generators and other equipment were present until recently, and the release of dielectric fluids caused the large industrial building at the site to become PCB contaminated. On three occasions, it became necessary for EPA to expend Superfund monies to address releases at the site. Michael Towle, EPA Remedial Project Manager, lead a team which remediated the site to commercial/industrial standards.

Risk Management

RT prepared a risk assessment review for the site to help demonstrate that contaminants which remain at the site are of limited concern. RT investigated the site and installed borings and monitoring wells to provide site-specific data to support Brownfields and Land Recycling initiatives. EPA has requested, as part of a Prospective Purchase Agreement that the floor of the building be remediated to residential standards prior to residential redevelopment.

A new surface PCB remediation technique, offered by NETC, will be used to remediate sections of the floor which are to remain at below residential standards. Other remedial needs at the site include remediation of a floor drain area and UST removal. A PADEP Land Recycling grant, and potentially, a Brownfields grant will help fund remedial activities, which are expected to take two to three months to complete. RT has already demonstrated that groundwater at the site is not impacted and a stream running through the site (Parke Run, a tributary to the Brandywine Creek) is viewed as an important asset to be worked into the redevelopment scheme for the site.

Redevelopment

Downingtown Borough supports the residential redevelopment of the site because surrounding areas are residential and the site is close to the downtown business area. The Downingtown Main Street Association, through its Director, Barry Cassidy, is actively helping to move the project forward. PADEP has reviewed the project, which is going through Pennsylvania's award winning Land Recycling Program. Bruce Beitler, PADEP's Land Recycling Coordinator, approved the project as being acceptable for an Act 2 Grant.

The majority of the site will see residential redevelopment including apartments and/or townhouses. Massive foundations from the heavy industrial buildings at the site are planned to be used as residential building foundations and/or as a base for parking lots. A developer is expected to be selected for the site shortly, and site plan and local approval processes will also be under way in the near future.

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